Robert and Linda Yuen - Page 9

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               failure to abate interest with respect to certain taxpayers.           
                         Explanation of provision                                     
                    The bill grants the Tax Court jurisdiction to                     
               determine whether the IRS's failure to abate interest                  
               for an eligible taxpayer was an abuse of discretion.                   
               The Tax Court may order an abatement of interest.  The                 
               action must be brought within 180 days after the date                  
               of mailing of the Secretary's final determination not                  
               to abate interest.  An eligible taxpayer must meet the                 
               net worth and size requirements imposed with respect to                
               awards of attorney's fees.  No inference is intended as                
               to whether under present law any court has jurisdiction                
               to review IRS's failure to abate interest.                             
                         Effective date                                               
                    The provision applies to requests for abatement                   
               after the date of enactment.                                           
               The Commissioner's authority to abate interest assessments             
          attributable to errors and delays by an officer or employee of              
          the IRS originated with the enactment of section 6404(e) under              
          the Tax Reform Act of 1986 (TRA 1986), Pub. L. 99-514, sec.                 
          1563(a), 100 Stat. 2085, 2762.  The Commissioner is authorized to           
          abate interest accruing with respect to deficiencies or payments            
          for tax years beginning after December 31, 1978.  See TRA 1986,             
          sec. 1563(b), 100 Stat. 2762.                                               
               Respondent maintains that we lack jurisdiction under section           
          6404(g) to review the rejection or denial of petitioners' request           
          for abatement of interest for 1990 on the ground that                       
          petitioners' original request for abatement of interest was filed           
          and denied prior to July 31, 1996--before section 6404(g) went              
          into effect.  Petitioners counter that the resubmission of their            

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